In Brief
A retired daily-wage worker, later regularized as a State Government employee, sought gratuity under the Payment of Gratuity Act, 1972. The High Court dismissed the claim on the ground that State employees governed by separate service rules are excluded from the Act. The Supreme Court found conflicting precedent: an earlier unreported decision excluded such workers from gratuity if they lacked qualifying service under the rules, while a recent reported decision (Netram Sahu) had granted it without considering those rules. To resolve this conflict and ensure judicial propriety, the Court referred the matter to a larger three-judge Bench for authoritative determination."
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